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783 KB
Extraction Summary
4
People
3
Organizations
1
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Court filing / legal brief (government response)
File Size:
783 KB
Summary
This document is a page from a Government filing in the case against Ghislaine Maxwell (Case 1:20-cr-00330), dated March 11, 2022. It discusses a dispute regarding 'Juror 50', who has requested access to his own voir dire transcript and juror questionnaire; the defense opposes this, arguing it would prejudice the investigation into the juror's conduct, while the government supports the juror's right to access a document he authored. The text also references a separate motion by The New York Times to unseal juror questionnaires.
People (4)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror / Subject of Inquiry |
Subject of a post-trial investigation regarding juror conduct; requesting access to his own questionnaire and voir di...
|
| Juror 50's Counsel | Attorney |
Representing Juror 50 in the motion to acquire documents.
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| The Defendant | Defendant |
Opposing Juror 50's request; implied to be Ghislaine Maxwell based on case number 1:20-cr-00330.
|
| The Government | Prosecution |
Submits that Juror 50 should receive a copy of his own questionnaire.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The New York Times Company |
Moved to unseal juror questionnaires on January 24, 2022.
|
|
| Department of Justice (DOJ) |
Indicated by Bates stamp DOJ-OGR-00009843.
|
|
| Supreme Court |
Cited in legal precedents (U.S. citations).
|
Timeline (2 events)
2022-01-24
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in case citation Press-Enter. Co. v. Superior Ct. of California.
|
Relationships (2)
The defendant opposes Juror 50’s request for his questionnaire.
Government submits that Juror 50 should get a copy of his own questionnaire.
Key Quotes (5)
"The defendant opposes Juror 50’s request, describing it as a 'discovery request' and claiming that the release of Juror 50’s questionnaire would prejudice the 'investigation' of Juror 50’s 'conduct'"Source
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Quote #1
"undoubtably color Juror No. 50’s testimony and allow him to place himself in the best possible posture."Source
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Quote #2
"Juror 50 is not a defendant and he is not seeking discovery."Source
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Quote #3
"He is asking for access to his questionnaire: a document that he himself prepared and swore under penalty of perjury"Source
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Quote #4
"The privacy concerns that otherwise might require limiting access to Juror 50’s questionnaire plainly do not apply to Juror 50 himself or his counsel."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,382 characters)
Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 45 of 49
into the subject, by allowing [him] an opportunity to fully and fairly brief the Court on the relevant
issues.” (Id. at 7).
issues.” (Id. at 7).
In his motion, Juror 50’s counsel requested a copy of Juror 50’s questionnaire, as well as
the transcript of his testimony during voir dire. (Juror 50 Mem. at 4). The defendant opposes Juror
50’s request, describing it as a “discovery request” and claiming that the release of Juror 50’s
questionnaire would prejudice the “investigation” of Juror 50’s “conduct” and “undoubtably color
Juror No. 50’s testimony and allow him to place himself in the best possible posture.” (Def. Mem.
at 52-53). As an initial matter, the Government notes that Juror 50’s voir dire was conducted in
open court and is therefore available to Juror 50 and his counsel. As to the request for his
questionnaire, the Government submits that Juror 50 should get a copy of his own questionnaire.
the transcript of his testimony during voir dire. (Juror 50 Mem. at 4). The defendant opposes Juror
50’s request, describing it as a “discovery request” and claiming that the release of Juror 50’s
questionnaire would prejudice the “investigation” of Juror 50’s “conduct” and “undoubtably color
Juror No. 50’s testimony and allow him to place himself in the best possible posture.” (Def. Mem.
at 52-53). As an initial matter, the Government notes that Juror 50’s voir dire was conducted in
open court and is therefore available to Juror 50 and his counsel. As to the request for his
questionnaire, the Government submits that Juror 50 should get a copy of his own questionnaire.
The defendant has characterized Juror 50’s request for his own questionnaire as a
“discovery request,” but Juror 50 is not a defendant and he is not seeking discovery.18 He is asking
for access to his questionnaire: a document that he himself prepared and swore under penalty of
perjury, and which, now that trial is complete, is maintained under seal principally if not entirely
to protect his own privacy interests. See, e.g., Press-Enter. Co. v. Superior Ct. of California,
Riverside Cty., 464 U.S. 501, 511-12 (1984). The privacy concerns that otherwise might require
limiting access to Juror 50’s questionnaire plainly do not apply to Juror 50 himself or his counsel.19
“discovery request,” but Juror 50 is not a defendant and he is not seeking discovery.18 He is asking
for access to his questionnaire: a document that he himself prepared and swore under penalty of
perjury, and which, now that trial is complete, is maintained under seal principally if not entirely
to protect his own privacy interests. See, e.g., Press-Enter. Co. v. Superior Ct. of California,
Riverside Cty., 464 U.S. 501, 511-12 (1984). The privacy concerns that otherwise might require
limiting access to Juror 50’s questionnaire plainly do not apply to Juror 50 himself or his counsel.19
18 The defendant claims that courts have “refused discovery to individuals or entities under
investigation” “[u]nder analogous circumstances.” (Def. Mem. at 53). But in support of that
argument, the defendant cites only John Doe Agency v. John Doe Corp., 493 U.S. 146 (1989),
which is clearly not analogous as it involved a request under the Freedom of Information Act and
an ongoing grand jury proceeding.
19 On January 24, 2022, the New York Times Company moved to unseal, among other things, the
filled-out questionnaires for the twelve seated jurors. (Dkt. No. 583). The Government intends to
address that motion on or before February 11, 2022 in accordance with the Court’s January 26,
2022 order (Dkt. No. 585).
investigation” “[u]nder analogous circumstances.” (Def. Mem. at 53). But in support of that
argument, the defendant cites only John Doe Agency v. John Doe Corp., 493 U.S. 146 (1989),
which is clearly not analogous as it involved a request under the Freedom of Information Act and
an ongoing grand jury proceeding.
19 On January 24, 2022, the New York Times Company moved to unseal, among other things, the
filled-out questionnaires for the twelve seated jurors. (Dkt. No. 583). The Government intends to
address that motion on or before February 11, 2022 in accordance with the Court’s January 26,
2022 order (Dkt. No. 585).
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DOJ-OGR-00009843
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